[The appeal against this decision is reported at [2001] BTC 438.]

Dr A N Brice, T Wallace.

Decision released 5 February 2001.

Capital gains tax – Arrangements between an existing company and two classes of shareholders under which two new companies issued shares to shareholders of existing company in respect of and in proportion to their holdings of shares in existing company – Whether arrangements within Capital Gains Tax Act 1979, s. 86 – Whether for purposes of or in connection with a scheme of reconstruction.

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